FCPA Due Diligence Benefits


Developing a FCPA due-diligence process on third parties and their intermediaries can reap multiple economic benefits.

  • Avoid fines which are equal to or as a multiple of the possible economic gain.
  • Avoid a decline in the company’s market capitalization from having been implicated in an FCPA enforcement action.
  • Avoid having the imposition of a court appointed monitor to provide oversight, which the company will have to fund.


A combination of risk patterning, list matching and transactional analysis using information technology can analyze millions of lines of data allowing companies to focus their limited compliance resources where they are needed most.


In the News

“Westinghouse Air Brake Technologies Corporation (“Wabtec”) will pay about $675,000 and enter into a deferred prosecution agreement to resolve Foreign Corrupt Practices Act offenses caused by its Indian subsidiary, Pioneer Friction Limited. In the Securities and Exchange Commission's administrative proceeding, Wabtec will disgorge $259,000 and prejudgment interest of $29,351. It will also retain an independent consultant to review and make recommendations concerning its FCPA compliance. The SEC's federal civil action further requires Wabtec to pay a civil penalty of $87,000. Separately, the company will pay a fine of $300,000 to the Department of Justice and enter into a non-prosecution agreement imposing a strict compliance program and further cooperation with the DOJ.”

Source: The FCPA blog

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